Prosecution Insights
Last updated: April 19, 2026
Application No. 18/003,725

USER EQUIPMENT OPERATION DURING AN INACTIVE STATE

Final Rejection §103
Filed
Dec 29, 2022
Examiner
SEFCHECK, GREGORY B
Art Unit
2477
Tech Center
2400 — Computer Networks
Assignee
Nokia Technologies Oy
OA Round
4 (Final)
69%
Grant Probability
Favorable
5-6
OA Rounds
3y 8m
To Grant
89%
With Interview

Examiner Intelligence

Grants 69% — above average
69%
Career Allow Rate
469 granted / 677 resolved
+11.3% vs TC avg
Strong +20% interview lift
Without
With
+20.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
59 currently pending
Career history
736
Total Applications
across all art units

Statute-Specific Performance

§101
3.7%
-36.3% vs TC avg
§103
56.9%
+16.9% vs TC avg
§102
22.6%
-17.4% vs TC avg
§112
7.5%
-32.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 677 resolved cases

Office Action

§103
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Amendment filed 3/9/2026 is acknowledged. Claim 7 has been amended. Claims 1 and 14 have been previously cancelled. Claims 2-13 and 15-21 remain pending. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 2-13 and 15-21 are rejected under 35 U.S.C. 103 as being unpatentable over Liberg et al. (US20230189181A1), hereafter Liberg, in view of Huang et al. (US20210259021A1), hereafter Huang. Regarding claims 12, 13, and 16, Liberg discloses a UE (Fig. 8, 9, 11, 12) comprising at least one processor (Fig. 9, processor 201), at least one memory/non-transitory computer readable medium (Fig. 9, memory 215, medium 221; paragraph 123) and computer program code (Fig. 9, programs 225; paragraph 40; program code) configured to perform a method (Fig. 1, 10A-B) comprising means for receiving (Fig. 9, RF interface 209; Fig. 11, obtaining module 1602), from a base station (i.e. gNB; Fig. 2, 4-8; Fig. 14, base station 520; paragraph 5, 19), provisioning of a plurality of pre-configured radio resources for data transmission during transition from connected to inactive state of the UE (Fig. 1, step 12 transitioning from connected/step 10 to inactive/step 14), wherein a pre-configured radio resource of the plurality of resources is associated with a set of one or more downlink transmission beams of the base station (paragraph 7-11; Fig. 2, 4-7; Fig. 10, steps 1016-1024; RRC inactive mode uplink transmission associated with plurality of downlink reference signals to be measured/selected from for the uplink transmission). Liberg further discloses means for acquiring validity information associated with one or more of the plurality of pre-configured radio resources (Fig. 10, steps 1012, 1028) and means for determining a valid pre-configured radio resource of the plurality of pre-configured radio resources based on at least the validity information (Fig. 11, determining module 1604; Fig. 1, step 16; Fig. 10, step 1026; paragraph 5-6, 32, 41, 69-74, 141; PUSCH transmission in RRC inactive mode dependent on the validity of TA at the time of transmission). Liberg further shows the UE in inactive state is configured with configured grant-based small data transmission (CG-SDT) initially associated with at least one pre-configured radio resource (paragraph 5; reducing signaling overhead for small data payloads based on configured grant for PUSCH), the UE detects whether the at least pre-configured resource assigned for CG-SDT is still valid, no longer the best one but still usable, or no longer valid (Fig. 1, step 12-14; Fig. 10, step 1026; paragraph 5-6, 32, 41, 67-74, 141; dependent on the validity of TA and conditions for invalidating the TA) and the UE uses the at least one preconfigured resource as configured initially for transmitting the new payload via CG-SDT (Fig. 1, step 16; paragraph 5-6, 32, 41, 67-74, 141; PUSCH transmission in RRC inactive mode dependent on the validity of TA at the time of transmission). Liberg discloses supporting PUSCH in RRC inactive mode based on an earlier configured grant (paragraph 5) but does not expressly disclose the UE detects the validity of the resource prior to a new payload in the UE’s buffer. Huang discloses an analogous method and apparatus for fallback action of small data transmission (Title) including the UE detects the validity of the resource prior to a new payload in the UE’s buffer (paragraph 294-323; PDCCH addressed to C-RNTI contains UL grant prior to a new transmission; if Msg3 buffer is empty, obtain the MAC PDU from the MsgA buffer and store in Msg3 and process the (previously) received UL grant value and indicate to lower layers for Msg3 transmission). It would have been obvious to one of ordinary skill in the art at the time of effective filing to modify Liberg where the UE detects the validity of the resource prior to a new payload in the UE’s buffer, as shown by Huang, thereby ensuring contention resolution for 2-step random access with fallback to a 4-step RACH ensuring small data transmission during an inactive state of the UE under various conditions. Regarding claim 15, The combination of Liberg and Huang discloses a system (Fig. 14, system 500) comprising UE of claim 16 (Fig. 14, UE 530) and a base station (Fig. 14, base station 520) comprising means for transmitting (Fig. 14, interface 526/527) to the UE validity information for constraining beam-received uplink data transmission during transition from connected to inactive state of the UE (Fig. 1, step 12 transitioning from connected/step 10 to inactive/step 14; Fig. 11, determining module 1604; Fig. 1, step 16; Fig. 10, step 1026; paragraph 5-6, 32, 41, 69-74, 141; PUSCH transmission in RRC inactive mode dependent on the validity of TA at the time of transmission) to select one of a plurality of modes for uplink data transmission (i.e. connected/inactive modes; paragraphs 6, 16; also i.e. random access/configured grant; paragraphs 38, 63) and a subset of beams for uplink transmission (paragraph 7-11; Fig. 2, 4-7; Fig. 10, steps 1016-1024; RRC inactive mode uplink transmission associated with a subset of downlink reference signals to be measured/selected from for the uplink transmission). Regarding claims 2 and 3, The combination of Liberg and Huang discloses pre-configured resources are PUSCH (paragraph 5, 6, 23) and means for transmitting uplink data during an inactive state using the valid pre-configured radio resource of the plurality of pre-configured radio resources threshold (Fig. 10, step 1026; Fig. 11, transmitting module 1606). Regarding claims 4 and 17, The combination of Liberg and Huang discloses the validity information comprises one or more radio quality-based thresholds of the valid pre-configured radio resource of the plurality of pre-configured radio resources (Fig. 10B; paragraph 24, 67-68). Regarding claims 5 and 18, Liberg discloses means for avoiding using a pre-configured radio resource associated with a strongest downlink transmission beam of the set of one or more downlink transmission beams if the pre-configured radio resource is an invalid pre-configured radio resource (paragraph 32, 67-73; conditions for invalidating the TA) but fails to expressly disclose fallback to a 4-step RACH based data transmission mode. Huang discloses an analogous method and apparatus for fallback action of small data transmission (Title) including fallback to a 4-step RACH based data transmission mode (paragraphs 509-513, 536; fallback actions including switch to 4-step random access for small data transmission with or without UL grant). It would have been obvious to one of ordinary skill in the art before the time of effective filing to modify Liberg by providing for fallback to a 4-step RACH based data transmission mode, as shown by Huang, thereby ensuring small data transmission during an inactive state of the UE under various conditions. Regarding claims 6 and 21, The combination of Liberg and Huang discloses an association between the pre-configured radio resource and the set of one or more downlink transmission beams is direct or indirect (Fig. 10B; uplink transmission can occur if 1st beam = 2nd beam). Regarding claims 7 and 19, The combination of Liberg and Huang discloses means for estimating a RSRP of one or more of the downlink transmission beams and using the estimated RSRP to determine the valid pre-configured radio resource of the plurality of pre-configured radio resources (paragraph 19-32, 61-73; beam-specific RSRP rather than cell-specific RSRP). Regarding claim 8, Liberg discloses means for selecting based on the validity information for uplink data transmission during an inactive state of the UE (paragraph 5-11, 32, 41, 69-74, 141; Fig. 2, 4-7; Fig. 10, steps 1016-1024; RRC inactive mode uplink transmission dependent on the validity of TA at the time of transmission) and at least one of the plurality of pre-configured radio resources that is associated with the set of one or more downlink transmission beams of the base station (paragraph 7-11; Fig. 2, 4-7; Fig. 10, steps 1016-1024; RRC inactive mode uplink transmission associated with a subset of downlink reference signals to be measured/selected from for the uplink transmission) but does not expressly disclose a plurality of modes for uplink data transmission during an inactive state of the UE. Huang discloses an analogous method and apparatus for fallback action of small data transmission (Title) including a plurality of modes for uplink data transmission during an inactive state of the UE (Abstract; paragraphs 509-513, 536; 2-step and 4-step RA with or without UL grant). It would have been obvious to one of ordinary skill in the art before the time of effective filing to modify Liberg by providing a plurality of modes for uplink data transmission during an active state of the UE, as shown by Huang, thereby ensuring small data transmission during an inactive state of the UE under various conditions. Regarding claim 9, The combination of Liberg and Huang discloses means for switching to a mode of data transmission based on the validity information (Fig. 1, step 14), wherein at least a set-up procedure for the mode of data transmission comprises configuration of radio resources for an aligned (i.e. synchronized) downlink transmission beam of the set of one or more downlink transmission beams (Fig. 1, steps 10-12; Fig. 5-7; paragraphs 5, 11, 15, 27, 71; validity of TA dependent on the location/corresponding SSB). Regarding claims 10 and 20, Liberg discloses means for selecting configured to select, in dependence upon a current downlink transmission beam of the set of one or more transmission beams not being a strongest downlink transmission beam of the set of one or more transmission beams and based on the validity information, a configured grant mode for uplink data transmission and the strongest downlink transmission beam (Fig. 10B, paragraphs 1144-146; 1st beam does not = 2nd beam, but the same TA is valid/above threshold, so inactive mode transmission occurs). Liberg does not expressly disclose selecting a random access mode for uplink data transmission when the current downlink beam is insufficient for uplink data transmission. Huang discloses an analogous method and apparatus for fallback action of small data transmission (Title) including selecting a random access mode for uplink data transmission when the current downlink beam is insufficient for uplink data transmission (paragraphs 488-490, 497-500, 509-513, 536; fallback actions including switch to 4-step random access for small data transmission with or without UL grant when radio/beam condition is below a threshold). It would have been obvious to one of ordinary skill in the art before the time of effective filing to modify Liberg by selecting a random access mode for uplink data transmission when the current downlink beam is insufficient for uplink data transmission, as shown by Huang, thereby ensuring small data transmission during an inactive state of the UE under various conditions. Regarding claim 11, The combination of Liberg and Huang discloses means for using the validity information to select one of a plurality of modes for uplink data transmission (i.e. connected/inactive modes; paragraphs 6, 16) and an estimated strongest available beam of the set of one or more downlink transmission beams for uplink transmission (paragraph 28, 32, 64-73). Response to Arguments Applicant's arguments filed 3/9/2026 have been fully considered but they are not persuasive. In the Remarks on pg. 10-14 of the Amendment, Applicant contends Liberg shows only one pre-configured resource (i.e. PUSCH) rather than “a plurality of pre-configured radio resources” as claimed. The Examiner respectfully disagrees. Applicant’s argument fails to consider the broadest reasonable interpretation of a “pre-configured radio resource”. One of ordinary skill would not limit their consideration of this limitation to the particular channel (PUSCH) or RACH preambles, as suggested by Applicant. Rather, and contrary to Applicant’s assertions, the SSBs of respective beams and their corresponding TA values, as illustrated in Liberg Fig. 7, would be considered as “pre-configured radio resources” as claimed. As such, Liberg’s disclosure of PUSCH transmission in RRC inactive mode using a particular TA value that is determined to be valid meets the contested limitations. Therefore, the rejections based on the combination of Liberg and Huang are properly maintained. In the Remarks on pg. 15-17 of the Amendment, Applicant contends Huang does not remedy the deficiencies of Liberg. The Examiner respectfully disagrees. As shown in the rejection, Liberg is relied upon to show the bulk of the claimed limitations. Huang is only relied upon to expressly show detecting validity of a resource prior to a new payload being transmitted from the UE’s buffer. Huang is not required to teach (or re-teach) those limitations shown in Liberg. Rather, it is the combination of Liberg and Huang, rather than either Liberg or Huang alone, that is considered in meeting the contested claims. One cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Therefore, the rejections based on the combination of Liberg and Huang are properly maintained. Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to GREGORY B SEFCHECK whose telephone number is (571)272-3098. The examiner can normally be reached Monday-Friday 6AM-4PM. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Chirag Shah can be reached on 571-272-3144. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /GREGORY B SEFCHECK/Primary Examiner, Art Unit 2477
Read full office action

Prosecution Timeline

Dec 29, 2022
Application Filed
Apr 23, 2025
Examiner Interview Summary
Apr 23, 2025
Applicant Interview (Telephonic)
May 05, 2025
Non-Final Rejection — §103
Aug 08, 2025
Response Filed
Aug 25, 2025
Final Rejection — §103
Oct 27, 2025
Response after Non-Final Action
Nov 26, 2025
Notice of Allowance
Nov 26, 2025
Response after Non-Final Action
Dec 03, 2025
Response after Non-Final Action
Dec 04, 2025
Non-Final Rejection — §103
Mar 09, 2026
Response Filed
Mar 23, 2026
Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
69%
Grant Probability
89%
With Interview (+20.0%)
3y 8m
Median Time to Grant
High
PTA Risk
Based on 677 resolved cases by this examiner. Grant probability derived from career allow rate.

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